Exhibit 1.01
Mazor Robotics Ltd.
Conflict Minerals Report
For The Year Ended December 31, 2017
This report for the year ended December 31, 2017 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (the “SEC”) to implement reporting and disclosure requirements related to Conflict Minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain Conflict Minerals that are necessary to the functionality or production of their products. "Conflict Minerals" are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (“3TG”) for the purposes of this assessment.
If a registrant can establish that the Conflict Minerals originated from sources other than the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”), or from recycled and scrap sources, it must disclose its determination, provide a brief description of the inquiry it undertook and the results of the inquiry on a Form SD.
If a registrant has reason to believe that any of the Conflict Minerals in their supply chain may have originated in the Covered Countries, or if they are unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the Conflict Minerals’ source and chain of custody. The registrant must annually submit a report, Conflict Minerals Report (the “CMR”), to the SEC that includes a description of those due diligence measures.
1. Overview
This report has been prepared by management of Mazor Robotics Ltd. (herein referred to as “Mazor”, "Mazor Robotics", "Company", “we”, “us”, or “our”). The information includes the activities of Mazor's wholly owned subsidiaries.
We are a leading innovator that has pioneered robotic guidance systems and complementary products in the spine and brain surgical markets which we believe may provide a safer surgical environment for patients, surgeons and operating room staff. We engage in the development, production and marketing of innovative medical devices for supporting surgical procedures in the fields of orthopedics and neurosurgery. We operate in the fields of image guided surgery and computer-assisted surgery enabling the use of surgical instruments with high precision and minimal invasiveness, aiming to simplify complex and minimally-invasive surgical procedures. We believe that our Mazor Core technology - the collaboration of four key technologies in Mazor's systems - provides predictable, efficient and precise surgical procedures. We believe that our portfolio of products, based on our proprietary Mazor Core technology and including the Mazor XTM Robotic Guidance System (“Mazor X), and the Renaissance® Surgical -Guidance System (“Renaissance” and together with the Mazor X, the “Products”), are transforming spine surgery from freehand procedures to highly accurate, state-of-the-art, guided procedures that raise the standard of care with better clinical results. We believe in evidence-based medicine, with more than fifty-five peer-reviewed studies validating the clinical value proposition of our products. The Mazor X, Renaissance and SpineAssist (our predecessor to the Renaissance) systems have been used to perform a wide variety of spine procedures on over 32,000 patients worldwide (with over 220,000 implants placed). We believe in ongoing innovation. In 2014, we introduced the Renaissance for brain surgery and in 2015 we introduced the PRO (Predictable Renaissance Operation) product line, which currently includes three solutions designed to support brain procedures, as well as, trauma and lateral spine procedures. We are continuing the development of the Renaissance platform for trajectory guidance in spine and brain surgery procedures. In July 2016, we unveiled the Mazor X system, a transformative robotic guidance platform for spine surgeries and in October 2016, we commercially launched the Mazor X system. The Mazor X system was developed with the goal of enhancing predictability and patient benefit, through the combination of analytical tools, multiple-source data, precision guidance, optical tracking, intra-op verification, and connectivity technologies. The Mazor X system was designed to expand the field of precision guided spine surgery beyond trajectory guidance. In April 2017, we received 510(k) clearance from the FDA for the Mazor X Align™ software, a spinal deformity correction planning software for the Mazor X system. The Mazor X Align is the first advanced application being integrated onto the Mazor X platform. We are continuing the development of the Mazor X platform for additional spine surgery procedures. On May 16, 2016, we entered into a strategic, two-phase Exclusive Lead Sharing and Distribution Agreement and a Purchase Agreement with Medtronic plc and certain of its affiliates (“Medtronic”). Under the first phase of this agreement, Medtronic was charged to generate sales leads for the Mazor X system. Mazor was stipulated as Medtronic’s sole strategic partner for development and commercialization of the Mazor X for robotic-based spine applications. In addition, Medtronic made certain investments in Mazor in 2016 and 2017. On August 30, 2017, we entered into the next phase of our strategic partnership with Medtronic, whereby Medtronic assumed exclusive global commercial responsibility for the Mazor X system for spine applications.
Our customers are mainly comprised of hospitals, medical centers, academic centers and medical device distributors.
Mazor is committed to high ethical standards and to conducting its business with a high level of integrity, as defined in our Code of Business Conduct and Ethics. We strive to source materials from companies that share our values regarding human rights, ethics and environmental responsibility.
We conducted an analysis of our Products and found the presence of 3TG materials. Therefore, the Products that we manufacture are subject to the reporting obligations of the Rule.
2. Supply Chain Overview
Mazor does not purchase Conflict Minerals directly from mines, smelters or refiners, and tracing these minerals to their sources is a challenge that requires us to rely on suppliers in the efforts to achieve supply chain transparency, including obtaining information regarding the origin of the Conflict Minerals. In order to manage the scope of this task, we integrated a responsible sourcing of minerals requirement within our Conflict Minerals Policy. Our suppliers are expected to provide the 3TG sourcing information to us per our Conflict Minerals Policy.
3. Reasonable Country of Origin Inquiry (RCOI)
We performed an internal assessment and prioritized the list of suppliers to approach. In the first step, we conducted a comprehensive analysis of our Products' components and identified potential 3TG Suppliers ("Potential 3TG Suppliers"). We contacted the identified Potential 3TG Suppliers to further investigate the possibility that 3TG minerals are present within our Products. We identified 164 Potential 3TG Suppliers whose products could potentially include 3TG.
We believe that implementing the OECD guidelines and using the Responsible Minerals Initiative ("RMI") (formerly the Conflict-Free Sourcing Initiative (CFSI)) Conflict Minerals Reporting Template (“CMRT”) to gather information from smelters and refiners are currently the best possible efforts to obtain mine and country of origin information.
Due to the size of the company, the breadth and complexity of our Products, and the dynamic nature of our supply chain, it is challenging to identify the source and origin of the 3TG incorporated in our Products. The manufacturing process for Mazor's Products is significantly removed from the mining, smelting and refining of Conflict Minerals, therefore, we must rely on our direct suppliers to assist us in obtaining information regarding the origin of the Conflict Minerals.
We reached out to those suppliers through letters and questionnaires designed to explain the relevant SEC requirements and Mazor's due diligence expectations as well as refer them to online training materials and instructions. Suppliers were asked to provide us with information regarding 3TG and smelters using the most recent CMRT developed by the RMI.
We engaged a global third-party service provider to compile the survey results, and we reviewed the responses that we received and followed up on what we perceived as inconsistent, incomplete, or inaccurate responses, as well as sent reminders to suppliers who did not respond to our requests for information. We received responses from 80 suppliers that represent 49% of our Potential 3TG Suppliers.
Based on information obtained, and taking into account the complexities of our supply chain, we do not have sufficient information from our suppliers to determine the country of origin of the Conflict Minerals used in our Products or the facilities used to process those Conflict Minerals. Therefore, we cannot exclude the possibility that some of these Conflict Minerals may have originated in the Covered Countries and are not from recycled or scrap sources.
Based on this result, Mazor undertook due diligence on the source and chain of custody of the Conflict Minerals that were necessary to the functionality or production of its Products during 2017. There is significant overlap between our RCOI efforts and our due diligence measures performed.
4. Due Diligence Program
4.1. Design of Our Due Diligence and Description of the Due Diligence Process
Our due diligence processes and efforts have been designed and developed based on the Organization for Economic Co-operation and Development's ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas ("OECD Guidance") and the related supplements for gold and for tin, tantalum and tungsten. This aforementioned guidance includes the following measures:
Step 1: Establish Strong Company Management Systems;
Step 2: Identify and Assess Risk in the Supply Chain;
Step 3: Design and Implement Strategy to Respond to Risks;
Step 4: Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Point in the Supply Chain; and
Step 5: Report Annually on Supply Chain Due Diligence.
4.2. Due Diligence Process
4.2.1. Establish Strong Company Management Systems
Our Conflict Minerals due diligence process includes: the development of a Conflict Minerals Policy; establishment of governance structures with cross functional team members and senior executives; communication to, and engagement with suppliers; due diligence compliance processes and measurement; record keeping and escalation procedures.
4.2.1.1. Conflict Minerals Policy
Mazor believes that ethical business conduct is critical to its operations and therefore has established a Code of Business Conduct and Ethics. Mazor is concerned that the trade of Conflict Minerals mined in the Covered Countries may be fueling human rights atrocities in the region. Therefore, Mazor has adopted a Conflict Minerals Policy. As described in the policy, Mazor strives to source materials from companies that share our values around human rights, ethics and environmental responsibility. We do not aim to eliminate sourcing from the Covered Countries, but to encourage suppliers to engage in ethical sourcing of the Conflict Minerals from the Covered Countries. We expect our suppliers to comply with our Conflict Mineral Policy. The Policy is available on the Company's website at https://www.mazorrobotics.com/index.php/en-us/investors/investor-documents/corporate-governance.
4.2.1.2. Management Systems and Internal Team
Mazor has created a Conflict Minerals taskforce and engaged with an external consultant to ensure compliance with the Rule. Our taskforce led by our Vice President Operations and Global Service ("VP Operations & Service") who joined the Company in 2017, and a team of subject matter experts from relevant functions such as supply chain, engineering and finance departments. The taskforce oversees ongoing communication with the Potential 3TG Suppliers, to obtain Conflict Minerals evaluation results, to perform the required procedures to ensure that the responses received from our suppliers meet the requirements of the Rule and to deal with all issues arising from the RCOI findings and the due diligence program.
4.2.1.3 Control Systems
We utilize the RMI’s CMRT to collect data and information from our suppliers in order to identify the origin of 3TG in our supply chain. We also engage a global third-party service provider to assist us with the identification of the smelters and refiners that process the 3TG in our Products.
Mazor has an established due diligence compliance process and has set forth documentation and record maintenance mechanisms to ensure that relevant documentation is retained in a structured electronic database for a period of at least 5 years.
4.2.1.4 Supplier Engagement
We sent letters to Potential 3TG Suppliers informing these direct suppliers that Mazor is subject to the Rule, advised them of Mazor's commitment to responsible sourcing of minerals, and indicated that their cooperation in the due diligence process is expected, including completion of the CMRT.
We have also engaged a global third-party service provider to facilitate training and outreach to suppliers, as well as to communicate, collect, validate and archive supplier responses.
In addition, a conflict minerals clause that requires suppliers to provide us with information about the source of 3TG and relevant smelters or refiners was added to our standard contracts.
4.2.1.5 Grievance Mechanism
Our Conflict Minerals Policy is available to the public on our website and provides the contact details for reporting concerns or further guidance regarding our Conflict Minerals program.
4.2.2. Identify and Assess Risk in the Supply Chain
As described above, we identified through a comprehensive analysis of our Products 164 Potential 3TG Suppliers. We reached out to those suppliers through letters and questionnaires designed to explain the relevant SEC requirements and Mazor's due diligence expectations as well as to refer them to online training materials and instructions. Suppliers were asked to provide us with information regarding 3TG and smelters or refiners using the CMRT developed by the RMI. We received responses from 80 suppliers.
We compared the information provided therein with the RMI's standard smelter list.
4.2.3. Design and Implement Strategy to Respond to Risks
Each CMRT received from our suppliers was entered into a database maintained by a global third-party service provider and was reviewed. For non-responsive suppliers or suppliers that provided unclear or incomplete responses, an escalation process was implemented to obtain complete and accurate required information, sometimes requiring multiple telephone and/or email contacts to further the data collection process. We communicate to all our suppliers the importance of compliance and have a Conflict Minerals management program in place to collect, analyze, store and monitor the results of our inquires. We also request any supplier found to be supplying us with Conflict Minerals from sources that support armed conflict in Covered Countries to establish an alternative source of Conflict Minerals that does not support such conflict. Our VP Operations & Service is briefed on an on-going basis and as required on the results of our due diligence efforts. In addition, the status of the Conflict Mineral Program and relevant updates are shared with the team on an on-going basis and as required.
4.2.4. Carry Out Independent Third Party Audit of Supply Chain Due Diligence
Mazor does not have direct sourcing relationships with Conflict Mineral smelters or refiners. Where possible, we have relied on third-party assurances and certifications, such as the RMI's Responsible Mineral Assurance Process (“RMAP”).
4.2.5. Report Annually on Supply Chain Due Diligence
Our Conflict Mineral annual report is available on the Company's website at https://www.mazorrobotics.com/index.php/en-us/investors/investor-documents/corporate-governance and is filed with the SEC.
5. Results of Assessment:
5.1. Survey Responses
As indicated above, the Products that we manufacture, or contract to manufacture, are highly complex, and typically contain thousands of components from many suppliers. Since there are generally multiple tiers between the mines that extract Conflict Minerals and our suppliers, we relied on our suppliers to provide information on the origin of the Conflict Minerals contained in components supplied to us.
We did not receive information at the product level from all of our suppliers, and therefore the Company cannot clearly identify the source of origin of all 3TG included in its products.
Based on information provided by our Potential 3TG Suppliers as well as by RMI, the results of our due diligence investigations as of the date of this Report are as follows:
Out of 164 Potential 3TG Suppliers:
17% of our Potential 3TG Suppliers were determined to be 3TG free.
32% of our Potential 3TG Suppliers were determined to supply 3TG.
Based on the information we received from Potential 3TG Suppliers, we identified 322 smelters or refiners, categorized by 3TG: (Gold 150, Tantalum 43, Tin 83, Tungsten 46), of which 266 smelters or refiners, or 83%, have been certified as Conflict Free by the RMI, or are currently engaged in an audit process ("Active"), as of the date of publication of this report. We have identified 12 smelters or refiners, or 4% that provided conflict minerals from recycled or scrap sources. 318 of the smelters or refiners in our supply chain survey, or 99%, are not from the Covered Countries. We identified 3 smelters that were not designated as conflict free by the RMI, and are from the Covered Countries. We are in on-going communication with the relevant Suppliers sourcing from the aforementioned smelters or refiners to manage risks, and their responses are still under evaluation by the Company, as of the date of publication of this Report.
Based on the information provided by the relevant suppliers as well as by RMI, as of the date of this Report, the facilities that may have been used to process the Conflict Minerals in our Products may include to the best of our knowledge the smelters and refiners listed in Annex I below.
Based on the information provided by the relevant suppliers as well as by RMI, as of the date of this Report, the mine countries of origin of the Conflict Minerals contained in our Products may include the countries listed in Annex II below.
Please note that information is not gathered on a continuous, real-time basis from Mazor's suppliers, and that, since the information comes from direct and secondary suppliers and independent third-party audit programs, Mazor can only provide reasonable (not absolute) assurance regarding the source and chain of custody of the necessary Conflict Minerals.
6. Continuous Improvement Efforts to Mitigate Risk
As we move forward with our due diligence program, we will continue working with our global supply chain to ensure responsible sourcing and assure compliance with international regulations, and will consider taking the following steps to improve the due diligence that we conduct to further mitigate any risk that the Conflict Minerals in our Products could benefit armed groups in the Covered Countries:
| | a. | Periodically engage with suppliers to attempt to increase the response rate to our inquiries and to improve the content of the supplier responses, including responses that were identified as incomplete, inconsistent or inaccurate. |
| | b. | Continue to conduct and report annually on supply chain due diligence for the applicable Conflict Minerals. |
| | c. | Request of any supplier found to be supplying us with Conflict Minerals from sources that support armed conflict in Covered Countries to establish an alternative source of Conflict Minerals that does not support such conflict. We do not aim to eliminate sourcing from the Covered Countries, but to encourage suppliers to engage in ethical sourcing of the Conflict Minerals from the Covered Countries. |
| | d. | Validate supplier responses regarding smelters and refiners using information collected from reliable industry certification programs. |
| | e. | Continue to compare smelters and refiners identified by our supply chain survey against lists of facilities that have received a third-party “conflict free” designation and to track those that have not received such a designation. |
| | f. | Continue to report to management on the findings of our supply chain risk assessment. |
Caution Concerning Forward-Looking Statements
Any statements contained in this report regarding future expectations, beliefs, goals, plans or prospects constitute forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Further, any statements that are not statements of historical fact (including statements containing the words "believes," "anticipates," "plans," "expects," "may," "will," "would," "intends," "estimates" and similar expressions) should also be considered to be forward-looking statements. The forward-looking statements included herein are based on current expectations and beliefs that involve a number of known and unknown risks and uncertainties. Examples of forward-looking statements in this document include statements relating to our future plans. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict. There are a number of factors that could cause events to differ materially from those indicated by the forward-looking statements in this document, including the risks associated with our suppliers not cooperating fully or at all with our efforts. Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by federal securities laws.
Annex I - List of smelters or refiners
| Metal | Smelter Name | Smelter Country |
| Gold | Metalor Switzerland | SWITZERLAND |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | Gold Mining in Shandong (Laizhou) Limited Company | CHINA |
| Gold | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | Heraeus Ltd. Hong Kong | CHINA |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
| Gold | LS-NIKKO Copper Inc. | KOREA (REPUBLIC OF) |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | Shonan Plant Tanaka Kikinzoku | JAPAN |
| Gold | AGR Mathey | AUSTRALIA |
| Gold | Amagasaki Factory, Hyogo Prefecture, Japan | JAPAN |
| Gold | Dowa | JAPAN |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Kinzoku Co., Ltd. | JAPAN |
| Gold | Nihon Material Co., Ltd. | JAPAN |
| Gold | MEM(Sumitomo Group) | JAPAN |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Asahi Refining Canada Ltd. | CANADA |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | Asaka Riken Co., Ltd. | JAPAN |
| Gold | Valcambi S.A. | SWITZERLAND |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | Fujian Zijin mining stock company gold smelter | CHINA |
| Gold | China Henan Zhongyuan Gold Smelter | CHINA |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | Royal Canadian Mint | CANADA |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Aurubis AG | GERMANY |
| Gold | JCC | CHINA |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | Materion | UNITED STATES OF AMERICA |
| Gold | CCR | CANADA |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL |
| Gold | Boliden AB | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN |
| Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Istanbul Gold Refinery | TURKEY |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY |
| Gold | PAMP S.A. | SWITZERLAND |
| Gold | Republic Metals Corporation | UNITED STATES OF AMERICA |
| Gold | SEMPSA Joyería Platería S.A. | SPAIN |
| Gold | Umicore Precious Metals Thailand | THAILAND |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | AU Traders and Refiners | SOUTH AFRICA |
| Gold | Bangalore Refinery | INDIA |
| Gold | Caridad | MEXICO |
| Gold | Cendres + Metaux S.A. | SWITZERLAND |
| Gold | Chugai Mining | JAPAN |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
| Gold | DODUCO GmbH | GERMANY |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| Gold | Guangdong Jinding Gold Limited | CHINA |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| Gold | Japan Mint | JAPAN |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
| Gold | Kazzinc | KAZAKHSTAN |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
| Gold | Lingbao Gold Co., Ltd. | CHINA |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | Modeltech Sdn Bhd | MALAYSIA |
| Gold | Morris and Watson | NEW ZEALAND |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | PX Precinox S.A. | SWITZERLAND |
| Gold | Remondis Argentia B.V. | NETHERLANDS |
| Gold | SAAMP | FRANCE |
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA |
| Gold | SAFINA A.S. | CZECH REPUBLIC |
| Gold | Sai Refinery | INDIA |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | So Accurate Group, Inc. | UNITED STATES OF AMERICA |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | T.C.A S.p.A | ITALY |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
| Gold | Tony Goetz NV | BELGIUM |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Gold | Torecom | KOREA, REPUBLIC OF |
| Gold | Umicore Brasil Ltda. | BRAZIL |
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA |
| Gold | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| Gold | L'Orfebre S.A. | ANDORRA |
| Gold | Morris and Watson Gold Coast | AUSTRALIA |
| Gold | Pease & Curren | UNITED STATES OF AMERICA |
| Gold | SungEel HiTech | KOREA, REPUBLIC OF |
| Gold | Italpreziosi | ITALY |
| Gold | Marsam Metals | BRAZIL |
| Gold | Planta Recuperadora de Metales SpA | CHILE |
| Gold | Safimet S.p.A | ITALY |
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
| Gold | Sudan Gold Refinery | SUDAN |
| Gold | African Gold Refinery | UGANDA |
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF |
| Gold | H.C. Starck GmbH Goslar | GERMANY |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA |
| Tantalum | H.C. Starck Ltd. | JAPAN |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
| Tantalum | ULBA | KAZAKHSTAN |
| Tantalum | F & X | CHINA |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA |
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Tantalum | Solikamsk | RUSSIAN FEDERATION |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN |
| Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited | CHINA |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
| Tantalum | Duoluoshan | CHINA |
| Tantalum | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | KEMET Blue Metals | MEXICO |
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA |
| Tantalum | LSM Brasil S.A. | BRAZIL |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | Mineracao Taboca S.A. | BRAZIL |
| Tantalum | NPM Silmet AS | ESTONIA |
| Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN |
| Tantalum | Jiujiang Janny New Material Co., Ltd. | CHINA |
| Tin | China Tin (Hechi) | CHINA |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | China Yunnan Tin Co Ltd. | CHINA |
| Tin | Funsur Smelter | PERU |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | PT Bangka Tin Industry | INDONESIA |
| Tin | INDONESIAN STATE TIN CORPORATION MENTOK SMELTER | INDONESIA |
| Tin | Chengfeng Metals Co Pte Ltd | CHINA |
| Tin | Brand RBT | INDONESIA |
| Tin | CV United Smelting | INDONESIA |
| Tin | Mineração Taboca S.A. | BRAZIL |
| Tin | OMSA | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Brand IMLI | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | Kundur Smelter | INDONESIA |
| Tin | Thai Solder Industry Corp., Ltd. | THAILAND |
| Tin | Metallo-Chimique N.V. | BELGIUM |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | PT Tinindo Inter Nusa | INDONESIA |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | Jiangxi Nanshan | CHINA |
| Tin | China Rare Metal Material Co., Ltd. | CHINA |
| Tin | Alent plc | UNITED STATES OF AMERICA |
| Tin | Fenix Metals | POLAND |
| Tin | PT Belitung Industri Sejahtera | INDONESIA |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | CV Dua Sekawan | INDONESIA |
| Tin | CV Gita Pesona | INDONESIA |
| Tin | CV Serumpun Sebalai | INDONESIA |
| Tin | CV Tiga Sekawan | INDONESIA |
| Tin | CV Venus Inti Perkasa | INDONESIA |
| Tin | Dowa | JAPAN |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| Tin | Estanho de Rondonia S.A. | BRAZIL |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA |
| Tin | Gejiu Jinye Mineral Company | CHINA |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | Melt Metais e Ligas S.A. | BRAZIL |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| Tin | Elmet S.L.U. | SPAIN |
| Tin | Modeltech Sdn Bhd | MALAYSIA |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | PT Babel Inti Perkasa | INDONESIA |
| Tin | PT Bangka Prima Tin | INDONESIA |
| Tin | PT DS Jaya Abadi | INDONESIA |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA |
| Tin | PT Inti Stania Prima | INDONESIA |
| Tin | PT Karimun Mining | INDONESIA |
| Tin | PT Kijang Jaya Mandiri | INDONESIA |
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA |
| Tin | PT Menara Cipta Mulia | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT O.M. Indonesia | INDONESIA |
| Tin | PT Panca Mega Persada | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | PT Sukses Inti Makmur | INDONESIA |
| Tin | PT Sumber Jaya Indah | INDONESIA |
| Tin | PT Tommy Utama | INDONESIA |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | Soft Metais Ltda. | BRAZIL |
| Tin | Super Ligas | BRAZIL |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tin | PT Bangka Serumpun | INDONESIA |
| Tin | Pongpipat Company Limited | MYANMAR |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Human Chun-Chang non-ferrous Smelting & Concentrating Co., Ltd. | CHINA |
| Tungsten | China National Non Ferrous | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
| Tungsten | Xiamen H.C. | CHINA |
| Tungsten | H.C. Starck GmbH | GERMANY |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
| Tungsten | ACL Metais Eireli | BRAZIL |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Haichuang Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA |
Annex II - List of possible countries of origin of Conflict Minerals
| ANGOLA |
| ARGENTINA |
| ARMENIA |
| AUSTRALIA |
| AUSTRIA |
| BELGIUM |
| BOLIVIA |
| BRAZIL |
| BURUNDI |
| CAMBODIA |
| CANADA |
| CENTRAL AFRICAN REPUBLIC |
| CHILE |
| CHINA |
| COLOMBIA |
| CZECH REPUBLIC |
| DEMOCRATIC REPUBLIC OF CONGO |
| DJIBOUTI |
| ECUADOR |
| EGYPT |
| ESTONIA |
| ETHIOPIA |
| FRANCE |
| GERMANY |
| GHANA |
| GUYANA |
| HUNGARY |
| INDIA |
| INDONESIA |
| IRELAND |
| ISRAEL |
| ITALY |
| IVORY COAST |
| JAPAN |
| JERSEY |
| KAZAKHSTAN |
| KENYA |
| LAOS |
| LUXEMBOURG |
| MADAGASCAR |
| MALAYSIA |
| MALI |
| MEXICO |
| MONGOLIA |
| MOZAMBIQUE |
| MYANMAR |
| NAMIBIA |
| NIGER |
| NIGERIA |
| PAPUA NEW GUINEA |
| PERU |
